27 Nov 2012

AML is for everyone- “….keep in mind that around the world it is recognized that AML/CFT regulations need to be applied not just to banks, but rather to a range of financial and other types of commercial institutions….

…… Why? The reason is that any way that you can move money – any way that value can be intermediated – can be abused by criminals for money laundering, since the motive of almost all criminal activity is financial profit. It is one thing to have rules in place, but the most important component is effective implementation.

……..When an institution fails to uphold its compliance obligations, this creates a vulnerability – a crack in the foundation upon which our defenses against criminal abuse are built. Hence, in any regulatory framework, but certainly in the AML/CFT area, it is essential that compliance expectations be backed by a credible enforcement mechanism, which in FinCEN’s case means the imposition of civil money penalties.

…….Not only does this hold accountable those regulated institutions which have not followed the rules, but it is only fair to the financial institutions that are trying hard to implement credible AML/CFT controls, including bearing the responsibilities associated with these controls.”

Peter S. Alvarado, Deputy Director, Financial Crimes Enforcement Network (FINCEN) – October 2012